1. Kitikmeot Inuit Association
Summary of Technical Issues

2. Technical Overview
This presentation provides an overview of concerns & recommendations made by the KIA during the review, with regard to:
Wildlife, Vegetation, and Human Health
Socioeconomic Development and Land Use
Water Quality and Hydrogeology
Fisheries
Geotechnical Engineering

3. Wildlife and Habitat (KIA-DEIS-01 & 02)
A. Concern:
Impact of traffic on wildlife not properly assessed.
Location of quality grizzly bear denning habitat not mapped.
B. Recommendations:
Present clear total traffic predictions for each section of road and use updated total traffic rates in assessments to wildlife.
Produce a habitat suitability map for grizzly bear denning and use it to assess impacts on overwinter survival and reproduction of bears.
C. TMAC Response:
01 Result of workshops will be in FEIS.
02 Will produce habitability map.

4. Wildlife and Habitat (KIA-DEIS-03 & 04)
A. Concern:
Camera monitoring of Caribou near the project.
Flight paths and altitudes of migrating birds and the impact of wind turbines.
B. Recommendations:
Adjust data ranges for cameras, re-analyze data (or use other data- e.g., collars) and adjust both conclusions and mitigation and monitoring programs.
Provided location and engineering specification of wind turbines along with migratory flight paths of birds, evaluate impact on bird and other wildlife, and include mitigation methods to minimize impacts.
C. TMAC Response:
03 Will present camera data.
04 Will provide relevant data to turbines in FEIS.

5. Wildlife and Habitat (KIA-DEIS-05 & 06)
A. Concern:
How wildlife lifespans and reproductive histories are considered in impact assessment.
Increased hunting access and harvest.
B. Recommendations:
FEIS should include, average lifespan, age at first reproduction, age ratios, frequency of reproduction, reversibility of population trends, in EIS methodology and refine impact ratings.
Revisit TK predictions on impacts of the project and communication about caribou presence on caribou harvesting. Devise more monitoring and adaptive management and hold more TK workshops on hunting in the project area.
C. TMAC Response:
05 & 06 Will provide additional information in FEIS.

6. Wildlife and Habitat (KIA-DEIS-07 & 08)
A. Concern:
Snow clearing of roads and effects on wildlife.
Statistical power for Zone of Influence (ZOI).
B. Recommendations:
Snow berms should be at a height that allow for wildlife crossing or have gaps that allow for crossing.
DEIS should have effect sizes, power values, and alpha-value for ZOI.
C. TMAC Response:
07 TBD.
08 ZOI results, effect sizes, and alpha-value will be provided in FEIS.

7. Wildlife and Habitat (KIA-DEIS-09 & 10)
A. Concern:
Assessment boundaries for predicting impacts to vegetation should be adjusted.
Residual effects outside the PDA.
B. Recommendations:
Adjust boundaries assumed to encapsulate impacts on vegetation. Incorporate abiotic factors or ensure that dustfall and vegetation monitoring will capture habitat impacts beyond the PDA and provide plans for dust mitigation, nutrient loading, and pH increases.
Develop a long-term adaptive invasive plant management plan and consider the collecting of native vegetation seeds and growing them at NATS centre.
C. TMAC Response:
09 Dust monitoring will be updated in Air Quality Management Plan (AQMP).
10 will be addressed in FEIS.

8. Human Health (KIA-DEIS-11 & 12)
A. Concern:
Bird Selection for use in Human Health Risk Assessment.
Fish sampling methodology of Arctic Char.
B. Recommendations:
Use ptarmigan in place of Canada goose or use several bird species that are consumed by Inuit.
Conduct active sampling or work with local fishermen to increase sample size for tissue metal samples for statistical analysis.
C. TMAC Response:
11 Ptarmigan will replace Canada goose in HHRA.
12 Additional baseline sampling will be done for fish.

9. Human Health (KIA-DEIS-13 & 14)
A. Concern:
Fish sampling methodology for Whitefish and Lake Trout.
Soil Ingestion and dermal exposure to soil assumptions.
B. Recommendations:
Complete additional baseline sampling with additional data for Whitefish and include in food chain model.
Use Health Canada (2012) soil ingestion rates and update results using this substitution.
C. TMAC Response:
13 Additional baseline sampling will be conducted.
14 TBD.

10. Human Health (KIA-DEIS-15 & 16)
A. Concern:
Food chain model.
Inorganic arsenic fraction.
B. Recommendation:
Conduct additional wildlife sampling for key species used in the food chain model.
Adjust factors for inorganic arsenic estimation from total arsenic to better reflect the meat food group.
Take a subset of field samples to directly measure inorganic verses organic concentrations of arsenic.
C. TMAC Response:
TBD.

11. Human Health (KIA-DEIS-17 & 18)
A. Concern:
Cadmium in Arctic Char.
Biotransformation Factor (BTF) for small mammals.
B. Recommendations:
Conduct additional sampling of marine fish to measure cadmium & establish baseline concentrations for Arctic Char.
Incorporate additional data for cadmium in marine fish (if above detection limits) into models and update HHRA.
Use more specific BTFs for metals in soil for small mammals.
C. TMAC Response:
17 Marine fish will be collected and results included in FEIS.
18 Additional literature research will be done and included.

12. Human Health (KIA-DEIS-19 & 20)
A. Concern:
Arctic Char effect on arsenic ILCR.
Lifetime cancer risk.
B. Recommendations:
Include further sampling of Arctic Char to determine if arsenic ILCR exceeds human health guidelines under baseline.
Update documents to reflect arsenic ILCR exceedances for human health guidelines under baseline conditions for Arctic Char. Include additional data and update in FEIS results on ILCR exceedances.
Provide an estimate of ILCR for reclamation, closure, and post-closure and an estimate of the total ILCR for all phases.
C. TMAC Response:
19 Additional char data will be included in FEIS.
20 TBD.

13. Human Health (KIA-DEIS-21 & 22)
A. Concern:
Fish uncertainty.
Vegetation sampling for food chain model.
B. Recommendations:
Collect additional fish samples for metal concentration analysis in Arctic Char and Whitefish and remove the “term conservative” from the DEIS description.
Complete sampling of vegetation that is typically consumed by wildlife and prevalent on site.
Run the models and complete EDI calculations using the new data.
C. TMAC Response:
21 Whitefish will be removed & lake trout dataset will be used for freshwater fish. 22 Surrogate data from other projects sites will be added.

14. Human Health (KIA-DEIS-23 & 24)
A. Concern:
Soil ingestion rates by caribou and muskox.
Additional fish tissue metal data.
B. Recommendations:
Update estimates of soil ingestion rates based on cited studies for caribou and muskox.
Present prior data for fish tissue metal concentrations in the human health section.
Update associated food chain model and human exposure scenario.
C. TMAC Response:
23 Soil ingestion rate will be updated in FEIS.
24 Additional char will be collected for fish tissue metal data.

15. Human Health (KIA-DEIS-25)
A. Concern:
Monitoring and mitigation.
B. Recommendations:
Add more concrete adaptive plans that include re- running HHRA and ERA models where modelled predications are exceeded.
Use updated HHRA or ERA as required and include results in annual reports based on monitoring values.
C. TMAC Response:
TBD.

16. Socioeconomic Development and Land Use (KIA-DEIS-27 & 28)
A. Concern:
Exclusion of population and demographic as VSEC and in turn, exclusion of effects assessment on community wellbeing.
Land use baseline methods.
B. Recommendations:
Explicitly discuss and assess population and demographic changes on regional and community wellbeing.
Additional workshops and interviews of Kitikmeot Inuit residents regarding all aspects of land and resource use and represent in the FEIS.
C. TMAC Response:
27 TBD.
28 Updated land use data will be incorporated in FEIS.

17. Socioeconomic Development and Land Use (KIA-DEIS-29)
A. Concern:
Commercial land and resource use; the characterization of effects and traditional activities and knowledge.
B. Recommendations:
Additional workshops and interviews are conducted with Kitikmeot Inuit residents regarding all aspects of land and resource use, land access and occupancy in relation to changes that have occurred since 2011 and that these changes be represented in the FEIS.
C. TMAC Response:
29 Updated land use data will be incorporated into FEIS.

18. Human Health (KIA-DEIS-30 & 31)
A. Concern:
HHERA, country food assessment.
HHERA, cumulative impacts.
B. Recommendations:
Implement tissue sampling program in collaboration with community members in support of country food assessment.
All phase of the project should be included in the assessment of potential health risks.
C. TMAC Response:
TBD.

19. Human Health (KIA-DEIS-32 & 33)
A. Concern:
HHERA, exposure assumptions.
HHERA, soil screening.
B. Recommendations:
Include the rationale for using half of the detection limit to calculate exposure point concentrations in the assessment.
More recent soil sampling should be conducted to confirm baseline conditions, or rationale for considering data several years old as representative of baseline is required.
C. TMAC Response:
TBD.

20. Fisheries (KIA-DEIS-34 & 35)
A. Concern:
Fisheries offsetting.
Habitat evaluation procedure to construct a habitat budget for Roberts Bay offsetting plan.
B. Recommendations:
Provide clarity on the specific impacts where offsetting is proposed to counterbalance losses.
Provide further details on how the impact (habitat losses) and proposed gains (offsetting) will be measured.
C. TMAC Response:
34 Will work with DFO to develop fish offsetting plan & quantify fish habitat loss in m^2.
35 Will work with DFO to determine most suitable approach to estimate fish productivity losses.

21. Fisheries (KIA-DEIS-36 & 37)
A. Concern:
Lake volume reduction in Imniagut Lake.
Loss or alteration of fish habitat, water withdrawal and use.
B. Recommendations:
Conduct additional baseline studies on the ecological function and fisheries community present in Imniagut Lake.
Provide details on how impacts are quantified and how changes in streamflow and lake levels from water withdrawals relate to changes in fish habitat.
C. TMAC Response:
36 Will conduct further baseline studies for Imniagut Lake.
37 Will improve clarity in FEIS on habitat losses and conduct additional field investigations in the summer of 2017.

22. Hydrogeology (KIA-DEIS-38 & 39)
A. Concern:
No sensitivity analysis of water balance on modelled mine groundwater inflows at Madrid.
Groundwater, sensitivity of lake infiltration to hydraulic properties.
B. Recommendations:
Conduct a sensitivity analysis of the water balance considering higher mine inflows, based on the results of the groundwater model sensitivity analysis, and conduct an updated effects assessment of freshwater fish habitat.
Consider changes in the sensitivity analysis; set K for fractured bedrock to at least one order of magnitude greater than the base value; set K for lake sediments to two orders of magnitude greater than the base value; set K for a hypothetical permeable fault to 1e-4 – 1e-5 m/s, depending on the assumed fault width.
C. TMAC Response:
38 TBD.
39 Uncertainty will be managed with groundwater management plan as with Doris North.

23. Water Quality (KIA-DEIS-40 & 41)
A. Concern:
Fate of wastewater from Boston Camp.
Prediction of Total Phosphorus in Aimaokatalok Lake and in Koignuk River.
B. Recommendations:
Confirm discharge location for treated domestic sewage effluent, it’s quantity, and duration.
Document effects from previous tundra discharges and their volumes.
Provide expected total phosphorus (TP) concentration in Boston WTP effluent.
Provide method used to predict TP concentrations in Aimaokatalok Lake and Koignuk River
Predict impacts of increased total phosphorus concentrations on nutrient status and dissolved oxygen conditions in Aimaokatalok Lake.
C. TMAC Response:
TBD.

24. Water Quality (KIA-DEIS-42 & 43)
A. Concern:
Guidelines used as assessment thresholds for freshwater quality.
Site runoff from Boston area.
B. Recommendations:
Please complete assessment for Total Suspended Solids (TSS) effects using the numerical CCME guideline.
Clarify if site runoff from Boston are will be collected and treated prior to discharge.
C. TMAC Response:
42 TBD.
43 Will consider source of runoff from roads and pads to see if a more representative value could be supported in light of results. May consider specific water quality objectives.

25. Climate and Fish (KIA-DEIS-44 & 45)
A. Concern:
Greenhouse gas emissions.
Food chain model for contaminants in fish.
B. Recommendations:
Provide adaptive management plan for greenhouse gas management and reduction.
Confirm if a food chain model for contaminants in fish was completed and used in the HHRA and ERA, if not update HHRA and ERA with a food chain model for fish.
C. TMAC Response:
44 Greenhouse gas emissions will be clarified in Air Quality Management Plan (AQMP).
45 TBD.

26. Water Quality (KIA-DEIS-46 & 47)
A. Concern:
Baseline lake data for water quality modeling.
Model calibration and validation.
B. Recommendations:
Conduct 2 years of multi-season baseline water quality sampling in lakes in the Doris\Madrid area as input into the water quality model and update model based on sampling.
Compare the modelled under-ice concentrations to measured values to verify the magnitude of cryo-concentration.
Provide rationale for the model not being calibrated to observed baseline data and validate the model and provide updated impact predictions.
C. TMAC Response:
46 Additional water quality data will be collected for water quality modelling.
47 TBD

27. Water Quality (KIA-DEIS-48 & 49)
A. Concern:
Flow and elevation model inputs.
Dry and wet year predictions.
B. Recommendations:
Provide an explanation and discussion of the effects of the limited baseline dataset on water and load balance and resultant impact predictions.
Regulatory Phase - Validate models and implement adaptive management and monitoring.
Model wet and dry years for each year of operations and closure, carry results forward to the effects assessment.
Complete a conservative analysis for two consecutive dry and two consecutive wet years to address uncertainty in climate change.
C. TMAC Response:
TBD.

28. Water Quality (KIA-DEIS-50 & 51)
A. Concern:
Criteria for residual effects covering project duration.
Criteria for residual effects concerning frequency.
B. Recommendations:
Revisit the short, medium, and long-term categories duration and link the criteria and definitions to potential affects on aquatic life and habitat.
Provide definition for “occasionally” as it pertains to the frequency of effect.
Differentiate between intermittent effects and infrequent effects.
Explain how effects were considered that occurred frequently, but were not intermittent or continuous.
C. TMAC Response:
TBD.

29. Water Quality (KIA-DEIS-52 & 53)
A. Concern:
Criteria for residual effect concerning reversibility.
Near field water quality predictions for Robert’s Bay.
B. Recommendations:
Provide definition of “acceptable time frame” as it pertains to reversibility of an effect.
Provide a table showing the predicted concentrations for parameters with CCME guidelines for Robert’s Bay at the edge of the mixing zone for Phase 2.
C. TMAC Response:
TBD.

30. Geotechnical Engineering (KIA-54 & 55)
A. Concern:
Contact Water Ponds.
Doris North TIA’s South and West dam stability assessments.
B. Recommendations:
Provide an assessment of the length of retention time required before negative thermal impacts would be experienced.
Site-specific ground information and updated stability analysis be reviewed during later stages of regulatory review.
C. TMAC Response:
54 & 55 Additional site investigation work and additional stability analysis will occur in later design stages.

31. Geotechnical Engineering (KIA-DEIS-56 & 57)
A. Concern:
Boston TIA’s dry stack stability.
Madrid North and South Waste Rock Piles’ stability.
B. Recommendations:
Site-specific ground water information and updated stability analysis be reviewed during later stages of regulatory review.
C. TMAC Response:
56 & 57 Additional site investigation work and additional stability analysis will occur in later design stages.

32. Geotechnical Engineering (KIA-DEIS-58)
A. Concern:
Contact water ponds’ stability and thermal performance.
B. Recommendations:
Site-specific ground information and updated thermal and stability analysis be reviewed during later stages of regulatory review.
C. TMAC Response:
58 Additional site investigation work and additional stability analysis will occur in later design stages.